May I pay a research subject to participate in my study?
Yes. PIs may pay research subjects as an incentive to increase recruitment and compensate them for their time, effort, and unreimbursed expenses incurred as a result of participating in the study. The IRB must approve the payment scheme prior to implementation.
Do I need IRB approval of my payment scheme?
Yes. If a PI is conducting human subjects research and intends to pay research subjects, then the PI must get IRB approval of the payment scheme prior to implementing the study. PIs can seek approval by outlining the payment scheme details in an IRB protocol and submitting it the the IRB. PIs should include details such as the payment type and amount, how and when the payment will be made, and what conditions the subjects must meet before qualifying for payment. PIs also must include these details within the informed consent documentation.
What factors must PIs consider in developing a research subject payment scheme?
PIs must ensure that payments will not coerce or unduly influence a research subject to participate in the study such that the subject's participation is not truly voluntary. PIs must consider the vulnerabilities of the subject population, what types and amounts of payment are appropriate in light of the demands of the study, what subjects must do in order to receive the payment, and the conditions under which the payment offer will be made. Additionally, in instances where PIs must collect personal information for tax purposes (see IRB Payments to Research Subjects Policy), PIs must consider how the information will be collected, stored, and shared with Accounts Payable, and how the payment will be recorded.
The IRB has approved my payment scheme in my IRB protocol, but now I need to make a change to the payment scheme. What should I do?
PIs who need to make a change to a previously approved payment scheme must submit an amendment request to the IRB. The PI may not implement any change until the IRB approves the amendment. The PI also should talk to Accounts Payable to be sure that the changes in the payment scheme can be implemented pursuant to Accounts Payable's policies and procedures.
May I pay non-research subjects (e.g. UI employees, contractors, sub-recipients, etc.) in connection with my study?
Yes, but the method of payment may be subject to certain restrictions. If the IRB determines during the review of a protocol that individuals who do not qualify as "research subjects" (see definition in IRB Payments to Research Subjects Policy) are going to be paid in connection with the study, the IRB will refer the matter to the Office of Sponsored Programs, who will work with the PI and UI's Finance Division to determine the appropriate payment mechanism. The determination of whether an individual involved in the project is a "research subject" or "non-research subject" is not always clear and must be made on a case-by-case basis in close consultation with the PI. For example, individuals involved in community-based participatory research projects generally will be deemed "research subjects" if they are not only participating in the design or implementation of the project, but also are in some way a source of data that is the focus of the project. However, individuals who merely provide a service in support of the project likely will be deemed employees, contractors, or sub-recipients; those individuals must be compensated through the payroll or contracting processes.
What methods are available to make payments to research subjects?
Subject to IRB approval and following the procedures in the IRB Payments to Research Subjects policy, PIs may provide research incentives to subjects via any of the following methods: (1) cash; (2) gift cards / gift certificates; (3) university checks; (4) non-cash tangible items; or (5) extra course credit. Note that monetary payments to nonresident alien individuals may be made by university check only, and PIs must issue those individuals a Form W-8. For monetary payments to U.S. tax residents in the amount of $50.01 or more, PIs must issue the subjects a Form W-9.
Do I have to collect subjects' personal information (name, address, SSN) in order to pay them?
It depends. If a PI pays a U.S. tax resident $50 or less, and the PI does not reasonably expect that aggregate payments to that person will exceed $600 in a calendar year, then the PI is not required to collect personal information from that subject. If a PI pays a U.S. tax resident $50.01 or more, reasonably expects that the aggregate payments to that person will exceed $600 in a calendar year, or pays any amount to a nonresident alien individual, then the PI is required to collect personal information from that subject. See the IRB Payments to Research Subjects policy for detailed guidance.
Do I have to share subjects’ personal information with UI Finance and Administration in order to make payments?
It depends. If a PI pays a U.S. tax resident $50.01 or more, reasonably expects that the aggregate payments to that person will exceed $600 in a calendar year, or pays any amount to a nonresident alien individual, then the PI must submit subjects’ personal information to Accounts Payable because the IRS requires the University to report all payments of $600 or more made to U.S. tax residents and payments of any amount made to nonresident alien individuals. The University also must send each of those individuals a Form 1099 or 1042-S, as applicable. In these circumstances, PIs must inform the research subjects that their personal information will be shared between University departments for payment and taxation purposes. PIs should contact Accounts Payable prior to making payments to ensure the proper safeguards are in place for transmitting the personal information.
How do I obtain a reimbursement or cash advance for research incentives?
Contact Accounts Payable prior to starting the research project and making any payments to determine the appropriate mechanism for receiving reimbursement or a cash advance. Accounts Payable will identify the documentation that PIs must produce in order to receive the reimbursement or cash advance.
May I purchase research incentives on my University P-card?
No. P-cards may not be used to purchase any research incentive including, but not limited to, gift cards, gift certificates, or non-cash tangible items.